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BarnesandNoble.com: Federal Court's nexus analysis reflects practical business realities.
Introduction
State taxing authorities have never much liked Quill and its "bright-line" physical presence rule. Even more vexing for some tax administrators seems to be the fact that Quill's rule, along with fundamental concepts of corporate law, often operates to insulate out-of-state companies from state taxation, even when the company is closely aligned with an in-state retail affiliate.
While the court cases in this area uniformly recognize that there is nothing inherently special about corporate affiliation for nexus purposes, state taxing authorities continue to aggressively target dot.com and catalog companies with local retail affiliates. Often, ...
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